In TransCore Holdings, Inc. v. Rayner, 104 S.W.3d 317 (Tex. App.--Dallas 2003, pet. denied), parties including TransCore and Rayner entered into a stock purchase agreement containing an arbitration clause. Id. at 319. Subsequently, the parties entered into a termination agreement that included a backward-looking mutual release of obligations and claims and a forward-looking provision requiring actions relating to the agreement to be brought in court. Id. at 320-21, 323. Rayner argued that the termination agreement released him from his obligation to arbitrate TransCore's claim that he made misrepresentations prior to termination. Id. at 321. The Dallas Court of Appeals agreed, noting that the termination agreement was a new agreement with new consideration that unconditionally released the parties from all previous obligations. Id. at 321-22, 323.